DEFRA consultation on MCZ proposals for designation in 2013 Response of the French fishing industry The following structures in different concerned regions of France were involved and/or are supporting the present response: National level Comité National des Pêches Maritimes et des Elevages Marins (CNPMEM) Union des Armateurs à la Pêche de France Nord Pas de Calais/Picardie Region CRPMEM du Nord Pas de Calais/Picardie Producers Organization «FROM NORD» Producers Organization «Coopérative Maritime Etaploise» Haute Normandie Region Basse Normandie Region CRPMEM de Haute Normandie CRPMEM de Basse Normandie Organisation de Producteurs Marins Pêcheurs de Basse Normandie Bretagne Region CRPMEM de Bretagne Producers Organization Les Pêcheurs de Bretagne Producers Organization COBRENORD 1/24
Preamble concerning the data used to support this response In the context of the implementation of the MCZ network and the Impact Assessment realized in order to estimate the costs and the benefits of these new MPAs, the French Ministry and Ifremer have implemented a web site showing the activity of French fishing vessels (number of vessels, number of hours and value, for 2008 and 2009) in the UK water. Regional MCZ Projects had access to this website during the MCZ identification process. Nevertheless, this website showed only the activity of the vessels equipped with VMS. However in the Eastern part of the Channel, there is a very important activity of vessels under 15 m which were not equipped with VMS in 2009. For example, in Nord Pas de Calais/Picardie, 70 % of the fleet is composed by vessels under 15 m. In early 2013, to complete this website, the French Ministry and Ifremer implemented documents representing the activity of the French fishing vessels within the MCZs, site by site, for 2008 and 2011, including data for the vessels not equipped with VMS. These documents contain following data: number of vessels, crew number, gears, landings in value and weight, economic dependency ratios, etc. Because of the time constraints, all documents could not be distributed now: some of them are not yet consolidated because they have not been appraised by fishing organizations. Consequently only some documents for the Eastern Channel and the North Sea could be distributed (attached to the present response). It should particularly be noted that the documents for the four South West and North West offshore sites of the 2013 designation tranche could not be yet distributed. For these sites, the data used to support this response come from the French Ministry/Ifremer website and a specific study realized by CRPMEM Bretagne and the Producers organizations Les Pêcheurs de Bretagne, as these sites mainly implicate the Brittany fishing fleet. Data used in this study are: data of fish sale for 2011 These data represent the sale of each boat month by month. data of French fleet activity in 2011. The method used is the "VALPENA" method developed by the laboratory Geolitomer, from the University of Nantes and the Regional Committee for marine fisheries and sea farming from Pays de la Loire. The method is based on interview of fishermen, asking them the localization of their fishing activity each month, in a sub division of 3*3 nautical miles of statistic rectangles. The fish sale's data are distributed linearly in each sub divisions of 3*3 nautical miles. 50% of fishermen working in this sector were investigated (53 surveys and 118 fishermen implicated). 2/24
For sites and features proposed in the 2013 tranche Q1. Do you agree that this site and specified features should be designated in the first tranche? Please explain and provide evidence to support your views as necessary. A.1 Regarding the French fishing activity, we can neither consider each zone individually chosen for public consultation, nor only the zones chosen in the first tranche. It is necessary to study all the zones together, to have a global vision. Actually, the whole zone highly modifies the space cutout and it will be the cumulative effects of each zone that will make fishing difficult in the English Channel and the Irish Sea. Moreover, it is very difficult to give our opinion on a site without taking into account the management measures that will be applied because they have to be compatible with the maintaining of fishing activities. Nevertheless, we want to give our opinion on the whole zone. The French Ministry and Ifremer implemented a web site showing the activity of the French fishing vessels (number of vessels, number of hours and turnovers, for 2008, 2009 in the UK water). Figure 1 and figure 2 are extracted from the French Ministry/Ifremer website: Figure 1: Number of vessels (mobile gears) in the MCZ in 2009 (DPMA website) 3/24
Figure 2: Number of vessels (static gears) 2009 (DPMA website) Following data are extracted from the Brittany specific study. The activity of the Brittany fishing fleet is underlined on the fifth map. Figure 3 represents the frequency rate of the Brittany fleet on Finding Sanctuary zones. Figure 3: Frequency rate of the whole Brittany fleet in Finding Sanctuary MCZ in 2011 (CRPMEM Bretagne & PDB 2012) 4/24
Figure 4 represents the production (in kg) of the Brittany fleet. Figure 4: Production (in kg) of the whole Brittany fleet in 2011 (CRPMEM Bretagne & PDB 2012) We can estimate that more than 50% of the vessels are dependent (in weight) on the zone for 10 15 % (Figure 5). Each month, approximately 10 vessels are dependent on the zones for more than 25%. Figure 5: Dependence of the Brittany fleet (in weight) on MCZ per month in 2011 (CRPMEM Bretagne & PDB 2012) Figure 6 represents the mean part in value of vessels turnovers of each site per month. Each site has an impact on 1 to 9% of the turnovers of vessels. So, global economic impact of 5/24
designed MCZ may be take into accound as a cumulative effect of the potential impact of each site on the annual turnovers of an individual boat. Moreover, the higher the number of sites, the more complicated the navigation will become, as well as the cost for fishing. It s an exponential logical effect. Figure 6: Estimated part in value (in ) of each site in 2011 The activity for the whole zones could not be considered as negligible or having a small economic cost on the industry. However, we want to answer as well as possible to this public consultation, thus, the activity of the Brittany fleet is presented for each MCZ. Site Name: East of Haig Fras According to Figure 7, the number of vessels fishing in the zone is relatively constant during the year (between 43 and 50 vessels) except for February where there are only 2 boats but which depend on this site on 2%. Furthermore, it appears that this site is important to some ships from Normandy. These fishing vessels are not referenced in Figure 7 because of the lack of precise data from the professional organization, but this tendency is confirmed by the final report from Finding Sanctuary (Final Report and Recommendation. September 7 th, 2011. P. 280). So a non negligible number of ships exploit this zone and it is the cumulative effect of the all proposed MCZ which has important negative consequences. 6/24
Figure 7: Number of vessels from Brittany frequenting the East of Haig Fras site and mean estimated production in this zone by months in 2011 Figure 8 represents the production of the Brittany fleet close to East of Haig Fras. We can notice that the production is mainly carried out in the south part of the site. Thus, it could be important to modify the boundaries of the zone considering the other sites with similar characteristics. Figure 8: Production (in kg) of the Brittany fleet in the sites linked to East of Haig Fras site in 2011 (CRPMEM Bretagne & PDB 2012) 7/24
The designation of East of Haig Fras seems possible in cases where: there is no total ban on trawl gears; or boundary has to be re considered and the south boundary has to heighten of 3 nautical miles up to the north direction Site Name: South West Deeps (West) According to the Figure 9, the number of vessels fishing is around 30, except during the forth quarter where about 10 boats are present. The percentage estimated part of the production in the zone is between 1% and 3% (maximum in May). Once again, a non negligible number of ships exploit this zone. Figure 9: Number of vessels frequenting the South West Deeps (West) site and mean estimated production in this zone by months in 2011 Figure 10 represents the production of the Brittany fleet close to South West Deeps (West). It could be important to modify the boundaries of the zone considering the other sites with similar characteristics. 8/24
Figure 10: Production (in kg) of the Brittany fleet in the sites linked to South west deeps (west) site in 2011 (CRPMEM Bretagne & PDB 2012) The indication of the site SWD (west) seems to be possible only if: There is no total ban on trawl gears; The South West Deep (east) is not designed in the second tranche. Indeed, habitats are mainly the same in the two sites so it looks logical to make a choice between those 2 sites, which will have a high economic impact on the fleets. Site Name: The Canyons Figure 11 shows that the number of vessels in the zone varies during the year. About 25 vessels are presented on the zone on the first part of the year, and the numbers decrease on the second part of the year (about 12 vessels). The mean estimated percentage of the production in the zone is comprised between 2% and 9%. We can notice seasonal fishing activity in this zone. 9/24
Figure 11: Number of vessels frequenting the Canyons site and mean estimated production in this zone by months in 2011 Figure 12 represents the production of the Brittany fleet close to the Canyons. It could be important to modify the boundaries of the zone considering the other sites with similar characteristics. Figure 12: Production (in kg) of the Brittany fleet in the sites linked to Canyon site in 2011 (CRPMEM Bretagne & PDB 2012) 10/24
Consequently, the indication of The Canyons site seems possible only if there is no total ban on trawl gears. Site Name: North of Celtic Deep Figure 13 shows that the number of vessels on the site varies during the year. There are between 15 and 34 ships from August to February. No fishing activity is noticed in the zone from March to July. The mean estimated percentage of the production in the zone is around 1% when the fleet is working. We can notice seasonal fishing activity in this zone. Figure 13: Number of vessels frequenting the North of Cetic deep site and mean estimated production in this zone by months in 2011 Consequently, the indication of North of Celtic Deep site seems possible only if there is no total ban on trawl gears. Q3. Do you have any comments on the proposed conservation objective(s)? Please provide evidence to support your comments as necessary. The close study of the environmental objectives in view of the propositions of management measures, or rather a ban on fishing, throws a light on the motivation of protecting the environment by the setting up of sanctuary zones. Indeed, objectives were fixed with very high levels. 15 to 30 % of each habitat have to be protected, which implies a proposition of 18 % of the total geographic area in MCZ, and consequently, in zones where fishing activities will be forbidden. This objective is not really compatible with maintaining fishing activity in the zone. With this new cutout of Community maritime space, the question of space sharing and its use is in the heart of the debate. The implementation of this project once again highlights the definition of a good quality of the marine environment. Is the aim to protect the functioning of the marine environment or is it to protect services for the well being of the society by well preserved ecosystems? In other 11/24
terms, is a rich biodiversity the main objective, knowing the fact that it wouldn t support human activities or resources, or preservation of the environment along with a development of human activities? Q4. Are there any significant reasons for alteration of this site s boundary? Please explain and provide evidence to support your views as necessary. Site Name: East of Haig Fras (refer to Question 1) We can notice that the production is mainly carried out in the south part of the site. Thus, it could be important to modify the boundaries of the zone considering the other sites with similar characteristics, notably the south boundary has to heighten of 3 nautical miles up to the north direction. Q7. Do you have any new information on costs to industry not covered in the Impact Assessment, that would be directly attributable to MCZs as opposed to costs stemming from existing regulatory requirements, or evidence that suggests the need for changes to the methodologies or assumptions used in estimating costs (including in relation to fishing displacement)? If yes please provide evidence. 1) For sites and features proposed in the 2013 tranche We want to present the economic impact in the sites designed in the first tranche in these two maps realized by the French ministry and Ifremer (Figure 14 et 15). Figure 14: Production in value of vessels (mobile gears) 2009 (DPMA website) 12/24
Figure 15: Production in value of vessels (static gears) 2009 (DPMA website) This information on costs for the French industry shows the importance of these sites for fishing activity. Indeed, these sites create several hundred thousand euros of turnover. The study realized by CRPMEM Bretagne and the Producers organizations Les Pêcheurs de Bretagne shows the impacts of these sites (Figure 16). This figure represents the part in value of each site per month. Figure 16: Estimated part in value (in ) of each site in 2011 Once again, we want to highligt the fact that it is the multiplication of sites that will lead to real difficulties for French fishing industry. Each site has an impact on 1 to 9% of the vessels. Negative impacts are quicly becoming higher than benefits. Moreover, the higher the number 13/24
of sites, the more complicated the navigation will become, as well as the cost for fishing. It s an exponential logical effect. 2) For sites and features proposed in Balanced Seas and Net Gain areas As said previously, the fleet in the Eastern Chanel is very heterogeneous. The Nord Pas de Calais/Picardie fleet is composed at 70 % by vessels under 15 m. In the Impact assessment lead in 2012, the information concerning the over 15 m fishing in the North Sea and the Eastern Channel was taken into account. In 2013, the French ministry has implemented documents representing the activity of the French fishing vessels within the MCZs, site by site, including data for the vessels not equipped with VMS. You will find these documents for 2008 attached to this response for the Balanced Seas MCZs (documents for 2011 are still in validation process). As you will see, there are some very important average dependency ratios, between 5% and 60 % (70% for some 10 12 m!). You will find too maps showing VMS data by static and mobile gears for 2012, for Balanced Seas area (Figures 17 & 18) and Net Gain area (Figures 19). Figure 17: VMS position for the French vessels (static gears) in 2012 Balanced Seas (DPMA Website) 14/24
Figure 18: VMS position for the French vessels (mobile gears) in 2012 Balanced Seas (DPMA Website) Figure 19: VMS position for the French vessels (mobile gears) in 2012 Net Gain (DPMA Website) We would like to underline our disappointment about the Silver Pit in the Net Gain area (Figure 20). Even if we know that the data contained in the DPMA Ifremer website were used in the Impact Assessment, we have already explained that the French activity within this area is very variable according to the year. You will find maps showing VMS data by gear for 2012 (Figure 20). It should not be forgotten that this site is concerned by a gentlemen s or goodwill agreement made in the Marine Fisheries Agency headquarters, 3 8 Whitehall Place, London, on Tuesday 31st October 2006. This arrangement is applied to the area known as the Silver Pit, called Zone C, and defined by the following coordinates: i. 53 35 N 00 41 E ii. 53 24 50 N 00 37 E 15/24
iii. 53 23 60 N 00 42 00 E iv. 53 26 00 N 00 40 00 E v. 53 31 00 N 00 42 20 E vi. 53 34 00 N 00 45 00 E vii. 53 35 00 N 00 45 20 E The area inside the box defined by these coordinates is an exclusive trawling zone (Site 6), so mainly French vessels. Same thing about the area extending north of a line extending from the 12 mile limit, eastwards without limit, at 53 54 North (Site 12). So this site will impact only the French fishing activity. Figure 20: VMS position for the French vessels (mobile gears) in 2012 Net Gain Zoom on Silver Pit (DPMA Website) 3) For sites and features proposed in Finding sanctuary area To underline the real challenge for the Brittany fleet in this area, 5 fleets have been defined with the following criteria: declared fishing zone, nature of captures. For each fleet, a model vessel has been defined, illustrating the dependence to the whole zones and not only one MCZ. 3.1) The following map and table (figure 21 and 22) represent the production in for model vessel of the South of Ireland fleet and the percentage of its turnover realize in each MCZ. 16/24
Figure 21: Production map (in ) for a model vessel of the South of Ireland fleet Figure 22: Production percentage (in, by month & by MCZ) for a model trawling gear vessel of the South of Ireland fleet 17/24
The South of Ireland fleet highly depends of the HAIG FRAS zones: Greater Haig Fras, North West of Jones Bank, North east of Haig Fras, East of Jones Bank & South West Deeps (east). As shown in the table for the model vessel (figure 22), more than 40% of his turnover can be realized in greater Haig Fras & east of Jones Bank zones. The main activity is realized around Haig Fras zone. Thus the ban of fishing inside this group, beyond the suppression of working area, will lead to a difficult boats circulation during the activity. 3.2) The following map and table (figure 23 and 24) represent the production in for model vessel of the West Accores Brittany fleet and the percentage of its turnover realize in each MCZ. Figure 23: Production map (in ) for a model vessel of the West Accores Brittany fleet 18/24
Figure 24: Production percentage (in, by month & by MCZ) for a model trawling gear vessel of the West Accores Brittany fleet The West Accores Brittany fleet is highly dependent of the South West deeps (East) zone as shown in the 2 figures. From December to April, 25% of the turnover is realized in this zone 3.3) The following map and table (figure 25 and 26) represent the production in for model vessel of the West Brittany end of English Channel fleet and the percentage of its turnover realize in each MCZ. 19/24
Figure 25: Production map (in ) for a model vessel of the West Brittany end of English Channel fleet Figure 26: Production percentage (in, by month & by MCZ) for a model trawling gear vessel oh the West Brittany end of English Channel fleet 20/24
The West Brittany end of English Channel fleet is highly dependant of the South West Deeps (east) zone, as the West Accores Brittany fleet. Between January and July, more than 35% of the turnover are realized in this zone and the other months, 15% of the turnover are realized in east of celtic deep, north of celtic deep, or greater Haig Fras. 3.4) The following map and table (figure 27 and 28) represent the production in for model vessel of the celtic sea/english Channel fleet and the percentage of its turnover realize in each MCZ. Figure 27: Production map (in ) for a model vessel of the Celtic sea / English Channel fleet 21/24
Figure 28: Production percentage (in, by month & by MCZ) for a model trawling gear vessel oh the Celtic sea / English Channel fleet The Celtic sea/english channel fleet is highly dependent of the Western Channel zone and Greater Haig Fras, East of Haig Fras, east of jones Bank. Nearly 15% of turnover is realized in these zones. In conclusion, this analyzes of the activity by fleet highlights the fact that all boats are not frequenting the whole zone. Each fleet has his well delimited fishing zone and is depending of one or more MCZ. Consequently, each delimited zones which its own management measures will have an important impact for fleets fishing in these zones. 4) General comments for all sites French data are available to regional projects (French ministry / Ifremer website of 2008 2009 fishing activity) were used partially in the Impact Assessment and this was welcomed by the French fishermen. Nevertheless, as indicated above, these data are incomplete because representing only the activity of VMS equipped vessels. In general, the estimated costs ("best estimate costs") were highly underestimated for all offshore sites and 6 12 miles sites since landings from the French vessels were not taken into account. Costs on the environment because of the displacement of fishing effort outside the MCZ and on fleets operating outside MCZs have not been quantified, but these fleets will 22/24
inevitably be impacted by displacement of fishing effort. Sites not concerned by fishing effort until now may be concerned in the future, resulting in a change in the footprint of fishing on the environment, and sites already fished will suffer a concentration of activity, resulting in problems of cohabitation and competition for resources in a space already crowded. In all cases, socio economic costs may not be known until management measures are decided. Until these measures are known, any estimate is highly uncertain. French professionals really wonder what the purpose of the designation MCZ network is: protection of the environment without any human activity or preservation of the environment in a sustainable development approach? Moreover, it seems very optimistic, especially for large areas proposed, to think that 75% of the vessels may postpone their fishing effort outside the MPA network British and French and areas concerned by other uses under development (marine energy, sand extraction), particularly in the English Channel. The socio economic impact assessment doesn t take into account the cumulative effects on fishing industry of the several Natura 2000, MCZ sites proposals, offshore windfarms projects etc. in the same geographical area. Impacts are calculated regarding only one site but many vessels are concerned by the different areas. These «cumulative» designations will limit the possibility to report the vessels activities if some additional regulations are implemented into the sites. If the dependence from each area could seem small, several vessels could be obliged to stop their activity because of the regulation adopted in the different sites and because of the cost for adapting their fishing strategy (increase of fishing time and/or transit time, adaptation of the gear or vessel) or unavailability of catch and effort quotas. The consultation document put forward that the sites with the highest socio economic costs ("top quartile Sites") will be designated only in specific cases, while showing a very important benefit. The mere inclusion of costs for French fleets would change cost categories of a number of sites: sites located beyond 6 nautical miles would probably end up in the top quartile, and not in the other quartiles. In addition, impacts on the whole sector have not been quantified: in France, it is estimated that one job at sea results in 4 onshore jobs. Furthermore, stopping the activity of a number of vessels could lead to a total deconstruction of coastal areas mainly based on fishing activities. The overall industry concerned by fishing (suppliers, buyers, processors, port services) is very important for the socio economy of those regions. A benefit put forward is the improvement of the state of fish and shellfish/crustaceans stocks for human consumption. However, for the moment there is no evidence that closing fishing areas will necessarily be beneficial for a stock, and in all cases, even if its condition improves, a stock that cannot be fished has no interest for human consumption. 23/24
Q9. You may wish to provide comments on other aspects of this consultation such as evidence requirements, identification and treatment of high risk sites. Where you disagree with the approach taken please provide evidence to support your views It is important to highlight the difficulties faced by Regional Committees for marine fisheries and sea farming (CRPMEM) and the National Committee for marine fisheries and sea farming (CNPMEM) and the Producers organisation Les pêcheurs de Bretagne during their involvement in the various regional projects affecting French fishermen. Very tight deadlines imposed to provide information and respond to various proposals, as well as a too small precision required leads to the non consideration of a number of quantitative data. The language barrier meetings not translated and the many, complex and voluminous documents available for consultation, made the involvement of French professional representatives difficult, as well as the difficulty of traveling, due tothe location of meetings (sometimes towns accessible with difficulty) and by reduced notice periods (sometimes a day ahead). In the particular case of Net gain, inability to participate in several subgroups was very problematic because French professionals fleets are concerned by all zones. French professionals also retain some fears and unanswered questions regarding MZCs. From the beginning of the process, the biggest uncertainty concerns the management measures that will be implemented in MCZs; uncertainty preventing professionals to a clear position on the proposed zones. A more difficult involvement of French professionals in regional projects (compared to British professionals) and a lesser consideration of the interests of foreign vessels (no direct survey as it was the case for British fishermen (Fisher Map), no quantitative socio economic assessment of foreign fleets,...) raised concerns about unequal treatment of British and foreign fishermen. Finally, as an essential point, French professionals remind that it will be absolutely necessary to create a working group with the fishing industry to dicuss the proposed management measures. The commitment should be made in the same time as the decision of designation. Sufficient time should be allowed for the proposed measures to be appropriate and sufficiently shared; they should also take into account economic constraints for the concerned fleets. 24/24